BankAmerica Corporation, as successor in interest to Continental Bank Corporation, as successor in interest to Continental Illinois Corporation - Page 4

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          issued on July 9, 1993.  Following this remand, the parties filed           
          with the Court on November 2, 1994, stipulated computations (the            
          1994 computations) covering the years 1976 to 1979.  The 1994               
          computations did not include the amounts of the 1979 ITC that               
          were included in the 1992 computations.  This Court's decision,             
          based on the 1994 computations, was entered on November 17, 1994,           
          and became final within the meaning of section 7481(a)2 on                  
          December 17, 1994 (the 1994 decision).  As part of that decision,           
          it was decided that there was an overpayment for the taxable year           
          1977 in the amount of $9,089,070.00, and a deficiency for the               
          taxable year 1978 in the amount of $1,544,492.72.  The decision             
          document indicated that it "[incorporated] herein the facts                 
          recited in the respondent's computation as the findings of the              
          Court".                                                                     
               Petitioner's tax liability for the taxable years at issue,             
          with the effect and timing of various credit and net operating              
          loss (NOL) carrybacks, reflecting the 1994 decision, is described           
          in more detail as follows:                                                  
               1977 Tax Year                                                          
               Petitioner had a tax liability for the 1977 tax year of                
          $24,200,118, before taking into account any credit carrybacks.              
          Between April 15, 1977, and June 17, 1978, petitioner made                  


          2  That section provides for a 30-day instead of a 90-day                   
          period for a decision of this Court to become final where there             
          has been a remand by the Court of Appeals.                                  




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